CA ANZ provided feedback to the International Valuation Standards Council (IVSC) on proposed changes to standards. We would like to thank our highly experienced CA Business Valuation Specialists on our Business Valuation Committee who contributed to this submission.

Our key points included:

• The proposed standards are, at times, more rules than principles-based which impedes interoperability with the professional practices required of our members and makes it difficult to scale to different size and types of valuations.
• We support a single set of global principles-based valuation standards, accompanied by a comprehensive and world leading glossary, which are concise, succinct and scalable. The standards, as they currently stand, do not reflect this.
• The IVSC should consider a wholesale review and rewrite of the standards, while being mindful to retain the valuable technical guidance they currently contain, to bring them in line with current practices.
• We applaud the IVSC for the ease of navigability of the extant IVS. However, in our view some of the proposed amendments in the ED add unnecessary complexity which in turn could negatively impact global adoption of the IVS.
• We recommend the scalability of the IVS is improved so that the requirements are proportional for smaller firms with low complexity. We are concerned that the ED, as currently drafted, makes the IVS even less accessible to smaller firms, increasing the barriers to adoption.
• We recommend the General Standards are principles-based, which would avoid unnecessary repetition in the Asset Standards and aid the understandability of the IVS as a whole. There is a large amount of duplication in the ED (e.g., Quality Control, Data and Inputs, and Documentation) which contributes to its length and in turn detracts from the effectiveness of the IVS.
• We support a clearer delineation between the mandatory requirements and the implementation guidance. As currently drafted, the mandatory requirements are obscured. We would also support the implementation guidance being located in a separate supplementary document.
• We recommend the proposed new requirements for quality control in section 30 of IVS 100 are revisited. We consider that they are inadequate as currently drafted in the ED.