The AICD has some concerns about the nature of the ED, particularly given the external environment in Australia and the heightened liability risks directors and entities are exposed to around the making of forward-looking statements. As a result, arrangements which may be suitable in other IFRS jurisdictions may not translate well into the Australian environment.

While generally supportive of the content of the ED, we think there is some scope for consolidation to reduce complexity and duplication.

Finally, we have some concerns around timing, given the likely effect of the IFRS Foundation Trustees’ project on sustainability reporting, the effect this may have on management commentary and the substantial focus it will require from preparers.

A copy of the submission is available here.