The AICD's submission noted 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, the submission argued that arrangements which may be suitable in other IFRS jurisdictions may not translate well into the Australian environment.

The submission stated that, while generally supportive of the content of the ED, the AICD thinks there is some scope for consolidation to reduce complexity and duplication. Finally, the AICD noted 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.

You can read a copy of the submission here.