Technical resource centre

The FRC have issued a project update relating to the ongoing periodic review of FRS 102 and FRS 105. In its update, the FRC noted that they received 54 response letters to FRED 82 and they are now preparing final amendments for issue which will take into account the responses received. Earlier this year, the Institute’s Financial Reporting Technical Committee issued a response to FRED 82. The FRC have indicated that they expect to issue the final amendments to FRS 102 and FRS 105 in the first half of 2024, with an expected effective date of periods commencing on or after 1 January 2026 for the changes. This is 1 year later than the date proposed in FRED 82. The FRC are working on amendments to the standards and provided updates on the revenue recognition and lease accounting sections which respondents provided feedback on during the consultation process. They will continue to work towards a “five-step model” for all FRS 102 and 105 preparers, while seeking simplifications to ensure proportionality for micro-entities. In addition to this, they have indicated that they will consider how to ensure that the “on-balance sheet” model of lease accounting under FRS 102 will be proportionate and understandable for FRS 102 preparers of all sizes.

The Institute has responded to the International Accounting Standards Board’s (IASB) request for information relating to IFRS 9 Financial Instruments impairment requirements. The IASB’s request for information begins the post-implementation review of IFRS 9’s impairment requirements and this allows the IASB to assess whether the effects of applying the new requirements on users of financial statements, preparers, auditors and regulators are those the IASB  intended when it developed the requirements. IFRS 9 has been effective for annual periods beginning on or after 1 January 2018. Some of the key points made by the Financial Reporting Technical Committee on behalf of the Institute include; Broadly speaking, the impairment model in IFRS 9 is working as intended and produces relevant and reliable information. There are some areas where users of the standard would benefit from additional guidance and educational material (for example- the definition of credit losses, calculation of expected credit losses on inter-group loans which are repayable on demand and interaction of impairment with other IFRS standards). There is a high cost of applying the impairment requirements to intercompany loans, often with limited benefit due to investors often placing greater reliance on the consolidated financial statements. The simplified approach for trade receivables, contract assets and lease receivables is working well in practice and is widely used. A recommendation that the IASB provide guidance regarding minimum disclosure requirements in IFRS 7 to achieve greater consistency in the information provided. The increasing prevalence of questions arising in relation to ESG risk when applying impairment requirements and the need for more guidance and educational material.

External assurance plays a key role in enhancing trust and confidence in financial and non-financial reporting. With the goal of enhancing the trust and confidence investors, regulators and other stakeholders have in sustainability information the International Auditing and Assurance Standards Board (IAASB) has developed a landmark, global sustainability assurance standard. This proposed International Standard on Sustainability Assurance (ISSA) 5000, General Requirements for Sustainability Assurance Engagements, was issued  for public consultation on August 2 and stakeholders have until December 1 to provide feedback and insights to the IAASB. The final standard will be issued before the end of 2024. Join the Irish Auditing & Accounting Supervisory Authority (IAASA) and IAASB webinar to hear about ISSA 5000.  Proposed International Standards on Sustainability Assurance Webinar - 29 September - 2pm You can register for the webinar at the following link: https://lnkd.in/e6ZetJKg You can find more information about the proposed standard on the website of the IAASB 

Welcome to this edition of Technical Roundup. In recent developments, Chartered Accountants Ireland are hosting a webinar Corporate Enforcement Authority – Insolvency on 5 October at 10am. This conversation is with Cathy Shivnan Director of Insolvency Supervision at the Corporate Enforcement Authority (CEA) and gives insights into the CEA’s insolvency agenda; the EU Commission has issued a guidance note for EU operators on implementing enhanced due diligence to shield against Russian sanctions circumvention. Read more on these and other developments that may be of interest to members below. Financial Reporting The UK Endorsement Board (UKEB) has issued a draft comment letter for public consultation in response to the IASB’s Request for Information on its Post-implementation Review (PIR) of IFRS15 Revenue from Contracts with Customers. The International Accounting Standards Board has published Exposure Draft Annual Improvements to IFRS Accounting Standards—Volume 11.  The document is available to download from the Open for comment section and from the individual project pages on the work plan. The European Single Markets Authority (ESMA) has published the annual update of its Reporting Manual on the European Single Electronic Format (ESEF). This includes technical improvements and additional clarifications. The European Financial Reporting Advisory Group (EFRAG) have issued their August update which summarises public technical discussions held and decisions taken during the month. In order for EFRAG to provide input to the initial phases of the IASB’s research project on the Statement of Cash Flows and Related Matters, EFRAG have issued an open call for tenders to assist in identifying uses and issues with the statement of cash flows. The IFRS Foundation has issued its August 2023 monthly news summary. This includes details of recent amendments to IAS 21, details of current consultations and requests for information and other matters of interest. Insolvency Chartered Accountants Ireland are hosting a webinar Corporate Enforcement Authority – Insolvency on 5 October at 10am. This conversation is with Cathy Shivnan, Director of Insolvency Supervision, at the Corporate Enforcement Authority (CEA) and gives insights into the CEA’s insolvency agenda. The session will include some background on Cathy’s career and her journey from Revenue to CEA along with the evolution of the CEA from the ODCE. This webinar is a free event and open to all. Earlier this week, the UK government published its response to the consultation on ‘The Future of Insolvency Regulation’, which ran between 21 December 2021 and 25 March 2022. The consultation sought views on a comprehensive package of reforms to the insolvency practitioner regulatory framework. This response includes a significant package of reforms which addresses the current weaknesses, closes a loophole in the framework, and provides opportunities for further reform. It will strengthen insolvency regulation and increase public confidence in the framework. Sustainability Accountancy Europe, in collaboration with the European Sustainable Business Federation, have issued a paper ‘5-step starting guide to a sustainable transition for SMEs’.  The paper presents 5 first steps an SME can take to begin their sustainable journey. It is vital to initiate the process, even with small steps, and gradually start preparing the business for what lies ahead. EFRAG and the Global Reporting Initiative (GRI) have issued a joint statement confirming that they have achieved a high level of interoperability between their respective standards in relation to impact reporting. EFRAG has published its final comment letters on the ISSB consultation on Agenda Priorities and SASB methodology. Sanctions The UK Financial Conduct Authority recently issued a publication on firms’ response to increased sanctions due to Russia’s invasion of Ukraine. In the publication the FCA set out key findings from its assessments of sanctions systems and controls and includes examples of good practice and areas for improvement. While the publication is in respect of financial services firms, the findings in relation to good practices and areas that need improvement may be of interest in any efforts to making improvements to the approach to identifying and assessing the sanctions risks that firms are exposed to. In September 2023 the EU Commission issued a guidance note for EU operators on implementing enhanced due diligence to shield against Russian sanctions circumvention. It is to help European operators to identify, assess, and understand the possible risks of Russian sanctions circumvention. It includes circumvention red flags related to business partners and customers and .The EU Guidance note is in the same vein as the summary AML Alert  Russia sanctions – Trade sanctions circumvention  which was  produced by the Accountancy AML Supervisors’ Group (AASG) from an extract from the UK Department of Business and Trade notice NTE 2023/08: Russia sanctions – Trade sanctions circumvention published 22 May 2023. Details of this notice were brought to members attention in a news item from Professional Standards Dept. of the Institute of August 23, 2023 where they alluded to awareness of the risk and obligations in relation to sanctioned goods as an important first step for those working in the accountancy profession so that they do not become party to the trade sanctions circumvention. Other News In September 2023 the UK Financial Conduct Authority (FCA ) announced a review of the treatment of domestic Politically Exposed Persons (PEPs) by financial services firms. The review will look at firms’ arrangements for dealing with PEPs based in the UK and will report by the end of June 2024. In the previous month of August 2023 it invited UK PEPs to share their experiences, including any problems they or their family members have encountered with the PEPs regime. The FCA has previously (in 2017 ) published guidance for how financial services firms should treat customers who are politically exposed persons when meeting their anti-money laundering obligations. The Financial Reporting Council (FRC) has welcomed the appointment of Peter Wyman CBE as the Institute of Chartered Accountants in England and Wales (ICAEW) first externally appointed Chair of the Board to modernise and strengthen the ICAEW’s governance and leadership. The Charity Commission for Northern Ireland is writing to over 250 charitable organisations, in preparation for work to begin on phasing out what is known as the “combined list”.  A list of all organisations the Commission is aware of, which may be charities but have not been registered yet, the combined list has been an integral part of the regulator’s work to manage registration of all charities in Northern Ireland. The European Securities and Markets Authority (ESMA), the EU’s financial markets regulator and supervisor, has published the annual update of its Reporting Manual on the European Single Electronic Format (ESEF). The Pensions Authority has published its 2022 Annual Report and accompanying statement from the Pensions Regulator. The Charities Regulator is holding a free webinar on Wednesday 27 September 2023 at 1pm to assist registered charities in preparing their annual reports. If you want to attend this you may register here. For further technical information and updates please visit the Technical Hub on the Institute website.

  In September 2023 the UK Financial Conduct Authority (FCA ) announced a review of the treatment of domestic Politically Exposed Persons (PEPs) by financial services firms. The review will look at firms’ arrangements for dealing with PEPs based in the UK and will report by the end of June 2024. In the previous month of August 2023 it invited UK PEPs to share their experiences, including any problems they or their family members have encountered with the PEPs regime. The FCA has previously (in 2017 ) published guidance for how financial services firms should treat customers who are politically exposed persons when meeting their anti-money laundering obligations.

On 1 September 2023, the Institute responded to the Financial Reporting Council (FRC) invitation for comments on their proposed changes to the “UK Corporate Governance Code” (‘Code’)*.  The proposed changes arise from a UK government request of the FRC to strengthen the UK Corporate Governance Code in specific areas following the recommendations arising from UK White Paper on “Restoring Trust in Audit and Corporate Governance” (‘White Paper’) published in 2022. Some of the key changes proposed to the Principles and Provisions applying to boards include: Setting out a revised framework of prudent and effective risk management and internal controls to provide a stronger basis for reporting on, and evidencing their effectiveness. Improving the quality of comply-or-explain reporting, taking account of recently published FRC research and reports, e.g. reducing boilerplate wording and requiring reports to demonstrate the outcomes of governance activities. Revising the responsibilities of the board and audit committee for sustainability and ESG reporting, and associated assurance in accordance with a company's audit and assurance policy. Aligning governance and reporting practices with changes to legal and regulatory requirements as set out in the Government's response to the White Paper, including strengthening reporting on malus and clawback arrangements. The Institute response welcomes FRC proposals that: discourage boilerplate reporting and encourage clear and concise disclosure on the reasons for any departure from the Code’s provisions, and how the Board has otherwise adhered to the overall principles of the Code. encourage consideration of and reporting (in accordance with established sustainability reporting standards) all material sustainability and ESG matters, including climate ambitions and transition planning, in defining business purpose, strategy, and values. increase the emphasis on workforce and broader stakeholder engagement, strengthening diversity and inclusion, and improves the effectiveness of remuneration policies and transparency. respond to some of the Chartered Governance Institute recommendations on board performance reviews and emphasis on improving board effectiveness. engage with emerging risks and opportunities such as artificial intelligence, for which the Institute have provided, in our response, some detailed considerations for inclusion in FRC guidance. Some of the key points highlighted in the Institute’s response focused on: The missed opportunity from limiting the update of the Code to reacting to legislative proposals rather than addressing learnings from corporate governance in recent years, including the principles and values (including ethics and healthy culture) that were lacking in respect of high-profile corporate failures. Highlighting the increasing role and responsibilities of Audit Committees, and the risks arising by mandating them as default for additional requirements versus ensuring the ability of the Board, who are ultimately responsible, to delegate roles and responsibilities as it sees fit in accordance with fiduciary duties. The lack of guidance and definitions for key terms used in the principles and provisions which, if provided, would provide for better understanding, and promote greater consistency, in many areas of the Code, including directors declarations on risk management and internal controls, audit and assurance policies, and narrative reporting. The importance of maintaining the principle-based approach to corporate governance that the Code has championed for over thirty years and to avoid deferring to requirements which are prescriptive, a matter of law and are not suited to a comply or explain model. The risk that established and effective practices for stakeholder engagement, reporting on future prospects and delegating oversight of sustainability matters may be lost based on the way some of the proposals are set out. The Chartered Accountants Ireland response to the FRC addressed all 26 questions and is available here. The FRC proposals are available on their website here. Níall Fitzgerald, Head of Ethics and Governance, Chartered Accountants Ireland   * The Code applies to premium listed companies on the London Stock Exchange and companies with a primary listing on the Irish Stock Exchange (and the Irish Corporate Governance Annex). Other organisations can voluntarily adopt the Code, for example, Chartered Accountants Ireland applies principles of the Code where they are relevant and commensurate to the Institute as a membership body.  

The UK Financial Conduct Authority recently issued a publication on firms’ response to increased sanctions due to Russia’s invasion of Ukraine. In the publication the FCA set out key findings from its assessments of sanctions systems and controls and includes examples of good practice and areas for improvement. While the publication is in respect of financial services firms, the findings in relation to good practices and areas that need improvement may be of interest in any efforts to making improvements to the approach to identifying and assessing the sanctions risks that firms are exposed to.

In September 2023 the EU Commission issued a guidance note for EU operators on implementing enhanced due diligence to shield against Russia sanctions circumvention. It is to help European operators to identify, assess, and understand the possible risks of Russian sanctions circumvention. It includes circumvention red flags related to business partners and customers that EU operators should watch for when they enter into a commercial relationship with a new trading partner . The EU Guidance note is in the same vein as the summary AML Alert  Russia sanctions – Trade sanctions circumvention  which was  produced by the Accountancy AML Supervisors’ Group (AASG) from an extract from the UK Department of Business and Trade notice NTE 2023/08: Russia sanctions – Trade sanctions circumvention published 22 May 2023  . Details of this notice were brought to members attention in a news item from Professional Standards Dept. of the Institute of August 23, 2023 where they alluded to awareness of the risk and obligations in relation to sanctioned goods as an important first step for those working in the accountancy profession so that they do not become party to the trade sanctions circumvention.

Technical Roundup is now published on the first and third Friday of every month – the next edition will be issued on 15 September 2023.